Gibbons v. Ogden (1824)

Provision of the Constitution in Action

Article I, Section 8 - broad vs. narrow interpretation of the Constitution

Government Action or Statue in Question

Does the power to regulate interstate commerce, granted to Congress by the Commerce Clause of the United States Constitution, encompass the power to regulate navigation, or is commerce power simply limited to buying and selling. Congress had exclusive national power over interstate commerce?

Major Doctrine

He condemned the view that the states and the federal government are equal sovereignties. Federal power is specifically enumerated, but within its sphere Congress is supreme. State legislation may be enacted in areas reserved to the federal government only if concurrent jurisdiction is feasible (as in the case of taxation).

Reasoning of the Majority

Marshall argued that — Commerce includes "every species of commercial intercourse" including navigation — Drew distinction between interstate state commerce (meaning more states than one) and intra state, i.e. commerce completely internal within one states — Interstate commerce has complete power to regulate, intra state reserved to states — Court does not answer whether Congress's power is exclusive or concurrent power (that states may exercise if congress does not) — Congress acted to regulate interstate navigation with 1793 statute providing coasting license — Ruled that gibbons licenses is valid, NY law interfered with interstate navigation and under supremacy clause is unconstitutional when applied to interstate commerce — National law overrides state law and that the national law is supreme within its sphere Since the Commerce Clause falls under the enumerated powers of Congress, no limits apply except those explicitly stated, no implied limits

Facts

Ogden gets a license to operate a steamboat between New York and New Jersey, Gibbons was his business partner. They split up, and Gibbons leaves Ogden, and gets a federal coasting license to operate a steamboat. Gibbons and Ogden are now in competition. Ogden sues in NY courts for an injunction because Gibbons does not have aNY license. Ogden wins, and Gibbon's boat is seized. Gibbons tries to appeal this in NY court and is unsuccessful, so he appeals to the Supreme Court.

Outcome

Supreme Court rules in favor of Gibbons

Alternative Solution

The opposing side argued that commerce power limited to buying and selling, not navigation — wanted a narrow interpretation of the commerce clause, and a limit on the powers of the federal government to regulate state activity